1.2 "Personal Data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of Personal Data could include name, identification number and contact information.
2. WHEN WILL WE COLLECT PERSONAL DATA?
2.1 We will/may collect Personal Data about you:
- when you register and/or use our Services or Site, or register an account with us;
- when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
- when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
- when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;
- when you use our electronic services, or interact with us via our mobile application or use services on our Site. This includes, without limitation, through cookies which we may deploy when you interact with our application or Site;
- when you carry out transactions or make payment related to any transactions through our Services;
- when you provide us with feedback or complaints;
- when you submit a job application to us;
- when you participate in contest, events, market research and surveys; or
- when you submit your Personal Data to us for any reason.
- The above are common instances of when Personal Data may be collected and does not purport to be exhaustive.
2.2 When you visit, use or interact with our mobile application or the Site, we may collect certain information by automated or passive means using a variety of technologies, which technologies may be downloaded to your device and may set or modify settings on your device. The information we collect may include, without limitation, your Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring website (if any), and the pages you visit on our Site and mobile applications and the times of visit. We may collect, use disclose and/or process this information only for the Purposes (defined below).
2.3 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more Purposes including, without limitation, location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your consent for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device's location services, please contact your mobile device service provider or the device manufacturer.
3. WHAT PERSONAL DATA DO WE COLLECT?
3.1 The Personal Data that we may collect include but is not limited to:
- Identity Card Number;
- Contact Number;
- Delivery Address;
- Date of Birth;
- Email Address;
- Bank Account details;
- Credit Card or Debit Card Information;
- Any other information about the user when the user signs up to use our Services or Site, as well as information related to how the user uses our Services or Site; and aggregate data on content the user engages with.
3.2 If you do not want us to collect your Personal Data, you may withdraw consent at any time by notifying us in writing about it. Further information withdrawing consent can be found in the section below entitled "How to withdraw consent, request access to or modify information you have provided to us?”. Note however that, by withdrawing your consent, it may affect your use of the Services.
4. SETTING UP AN ACCOUNT
In order to use certain functionality of the Services, you will have to create a user account which requires you to submit certain Personal Data. When you register and create an account, we require you to provide us with your name and email address as well as a user name that you select. We will also ask for certain information about yourself for example your phone number, email address, shipping address, photo identification, bank account details, age, date of birth, gender and interests. Upon activating an account, you will be able to access and maintain your account by using the user name and password that you have selected. select a user name and password.
5. COMMUNITY & SUPPORT
5.1 We provide customer service support through email, whatsapp, SMS and feedback forms. In order to provide customer support, we will ask for your email address and mobile phone number. We only use information received from customer support requests, including, without limitation, email addresses, for customer support services and we do not transfer to or share this information with any third parties.
6. HOW DO WE USE THE INFORMATION YOU PROVIDE US?
6.1 We may collect, use, disclose and/or process your Personal Data for one or more of the following purposes:
- to consider and/or process your application/transaction with us and/or providing you Services as well as services by third party service providers;
- to manage, operate, provide and/or administer your use of and/or access to our Services and our Site, as well as your relationship and user account with us;
- to manage, operate, administer and provide you with as well as to facilitate the provision of our Services, including, without limitation, remembering your preferences;
- processing any payments related to any transaction with us;
- to tailor your experience through the Services by displaying content according to your interests and preferences, providing a faster method for you to access your account and submit information to us and allowing us to contact you, if necessary;
- to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;
- to enforce our Terms of Service or any applicable end user license agreements;
- to protect personal safety and the rights, property or safety of others;
- for identification and/or verification;
- to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
- to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries, requests or complaints given by (or purported to be given by) you or on your behalf;
- to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain Personal Data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
- to allow other users to interact or connect with you on the Site, including to inform you when another user has sent you a private message or posted a comment for you on the Site;
- to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your customer experience;
- to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with our Services;
- where you give us your prior consent, for marketing and in this regard, to send you by various modes of communication such as postal mail, email, location-based services or otherwise, marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom we may collaborate or tie up with) that we may be selling, marketing or promoting, whether such products or services exist now or are created in the future;
- conducting credit/trade checks and other background checks on you with any registered credit reporting agency at any time for the purpose of processing a transaction with us or for as long as any dues remain unpaid and outstanding to us;
- for the purpose of credit evaluation, review or reporting and carrying out debt-collection or assisting other institutions to do so to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on us;
- to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
- to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
- to audit our Services or our business;
- to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
- to store, host, back up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside of your jurisdiction;
- to deal with and/or facilitate a business transaction or a potential business transaction, where such transaction involves us as a participant. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation; and/or
- any other purposes which we notify you of at the time of obtaining your consent
6.3 The purposes for which we will/may collect, use, disclose or process your Personal Data depends on the circumstances and are not limited to the above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.
7. SHARING OF INFORMATION FROM THE SERVICES
Our Services enable users to share personal information with each other, in almost all occasions without our involvement, to complete transactions. In a typical transaction, users may have access to each other’s name, user ID, email address and other contact and postage information. Our Terms of Service require that users in possession of another user’s Personal Data (the “Receiving Party”) to (i) comply with all applicable Privacy Laws; (ii) allow the other user (the “Disclosing Party”) to remove him/herself from the Receiving Party’s database; and (iii) allow the Disclosing Party to review what information has been collected about them by the Receiving Party.
8. HOW DO WE PROTECT AND RETAIN CUSTOMER INFORMATION?
8.1 We have security measures in place and we strive to ensure the security of your Personal Data on our systems. Your Personal Data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the Personal Data confidential. When you place orders or access your Personal Data, we offer the use of a secure server. All Personal Data or sensitive information you supply is encrypted into our databases to be only accessed as stated above. However, there can inevitably be no guarantee of absolute security.
9. DO WE DISCLOSE THE INFORMATION TO OUTSIDE PARTIES?
9.1 In conducting our business, we will/may need to disclose your Personal Data to third party(ies), whether based in Malaysia or outside of Malaysia, for one or more of the above-stated Purposes. Such third-party(ies) would be processing your Personal Data either on our behalf or otherwise, for one or more of the above-stated Purposes. Such third party(ies) include, without limitation to:
- our holding company, subsidiaries, affiliates and related corporations;
- other users of our platform for one or more of the above-stated Purposes;
- contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies, logistic companies and data centres;
- any registered credit reporting agencies under Credit Reporting Agency Act 2010;
- any law enforcement agencies;
- any governmental authorities or regulatory bodies;
- any other party authorised and consented by you; and
- our business partner, investor, assignee or transferee to facilitate business asset transactions (including without limitation to any merger, acquisition or asset sale).
9.2 This may require, among other things, share statistical and demographic information about our users and their use of the Services with suppliers of advertisements and programming.
9.3 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws allow us to collect, use or disclose your Personal Data without your consent, such permission granted by the laws shall continue to apply.
9.4 Third parties may unlawfully intercept or access Personal Data transmitted to or contained on the Site, technologies may malfunction or not function as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your Personal Data as required by the Privacy Laws; however, there can be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.
10. INFORMATION ON MINOR
11. INFORMATION COLLECTED BY THIRD PARTIES
11.2 We, and third parties, may from time to time make software applications downloads available for your use on or through the Services. These applications may separately access, and allow a third party to view, your Personal Data, such as your name, your user ID, your computer's IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third-party software application or website. These applications may ask you to provide additional information directly to them. Third party products or services provided through these applications are not owned or controlled by us. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.
11.3 In an attempt to provide you with increased value, we may choose various third-party websites to link to, and frame within, the Site. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third-party web sites (even if offered on or through our Site) may not be received by us.
11.4 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We therefore assume no responsibility nor liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Site and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).
12. HOW TO WITHDRAW CONSENT, REQUEST ACCESS TO OR MODIFY INFORMATION YOU HAVE PROVIDED TO US?
12.1 To withdraw consent
12.1.2 Once we have your clear withdrawal instructions and verified your identity, we will process your request for withdrawal of consent, and will thereafter not collect, use and/or disclose your Personal Data in the manner stated in your request. If we are unable to verify your identity or understand your instructions, we will liaise with you to understand your request.
12.1.3 However, your withdrawal of consent could result in certain consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we will not be able to continue providing the Services to you, we may need to terminate your existing relationship and/or the contract you have with us, etc., as the case may be, which we will inform you of.
12.2 Requesting Access and/or Modification of Personal Data
12.2.1 If you have registered account with us, you may personally access and/or modify your Personal Data currently in our possession or control through the “Me” settings page on the Site. If you do not have an account with us, you may request to access and/or modify your Personal Data currently in our possession or control by submitting a written request to us. We will request for information from you in order to verify or ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request by sending an email to us at the email address listed below in Section 13.1.
12.2.2 For a request to access Personal Data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant Personal Data within soonest possible time within which we can provide you with the information requested.
12.2.3 For a request to modify Personal Data, once we have sufficient information from you to deal with the request:
- we will modify your Personal Data within soonest possible time within which we can make the modification; and
- we may send the updated Personal Data to every other organisation to which the Personal Data was disclosed by us, unless that other organisation does not require the updated Personal Data.
12.2.4 Notwithstanding sub-paragraph (b) immediately above, we may, if you so request, send the updated Personal Data only to specific organisations to which the Personal Data was disclosed by us.
12.2.5 We will/may also be charging you a reasonable fee for the handling and processing of your requests to access your Personal Data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
12.2.6 We reserve the right to refuse to modify your Personal Data in accordance with the provisions as set out in Privacy Laws, where they require and/or entitle an organisation to refuse to correct Personal Data in stated circumstances.
13. CONTACT US
13.1 If you have any questions or concerns about our privacy practices or your dealings with the Services or complaint or grievance regarding how we are handling your Personal Data or about our compliance with Privacy Laws, please do not hesitate to contact:
E-mail: firstname.lastname@example.org and attention it to the "Legal Dept".
13.2 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a Privacy Law complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “Privacy Complaint”.
13.3 We will certainly strive to deal with any complaint or grievance that you may have fairly and as soon as possible.
14. TERMS OF SERVICE
Please also read the Terms of Service establishing the use, disclaimers, and limitations of liability governing the use of the Site and the Services and other related policies.